Lara Solano, Efren

Applicant Efren Lara Solano suffered catastrophic injuries (TBI, skull/facial/rib fractures, right thumb fracture) in a November 18, 2020 work accident when a truck rolled over him. He received post-acute residential rehabilitation at Casa Colina's Transitional Living Center from April 19 through October 1, 2021. State Compensation Insurance Fund authorized the first 14 days and resolved another 30 days by compromise, but disputed and sought $78,356 reimbursement for the remaining residential treatment, arguing applicant failed to seek IMR of its UR denials. The WCJ found SCIF's UR untimely under Labor Code section 4610(i), that applicant was entitled to concurrent review, that section 4610(i)(4)(C) barred discontinuation without an agreed safe discharge plan, and denied SCIF's reimbursement petition. The Appeals Board denied reconsideration, holding the UR determinations were untimely, that Patterson and Rivota barred unilateral discontinuation of authorized treatment absent proof of a change in condition, that no statutory or equitable basis supported reimbursement, and that a safe discharge plan agreed by applicant's physician was required.